RSS
How Daily Intake information pitfalls are likely to detract from usefulness and understanding of Nutrition Information Panels
Date Published13 December 2006
by Joe Lederman and Tony Zipper © Lawmedia Pty Ltd, December 2006
BALDWINS – FoodLegal
Australian Food Lawyers & Consultants
The concept of Percentage Daily Intake has recently received plenty of attention following the introduction by the Australian Food and Grocery Council of a voluntary scheme of Percentage Daily Intake labelling on the front of food packages. The concept is given even greater prominence with the draft of the proposed nutrition and health claims Standard 1.2.7 in FSANZ Proposal P293 requiring the mandatory declaration of Percentage Daily Intake when a nutrition or health claim is made. This 1,700 word article asks the question: Can Percentage Daily Intake values really help consumers understand nutrition information required by the Food Standards Code?
Percentage Daily Intake (%DI) information was first introduced into the Australia New Zealand Food Standards Code (ANZFSC) in December 2002, as clause 7 of Standard 1.2.8 and to a certain degree is modelled on the USA-FDA approach, except that the ANZFSC approach is optional. ANZFSC refers to the values of 100% Daily Intake as “Reference Value” whereas USA-FDA uses the term “Daily Value”. Another difference between the Australian and US approaches is that while the ANZFSC offers one set of “Reference Values”, the US approach provides a different set of “Daily Values” for men and women based on the assumption of different daily energy intake.
For comparison:
Note:
2000 calories = 8363 kJ
2500 calories = 10454 kJ
8700 kJ = 2100 calories.
Are the Reference Values meaningful and what is their source?
Background information on the Reference Values for Percentage Daily Intake figures is provided in Attachment 9 of the FSANZ User Guide on Nutrition Information Requirements.
Energy value is based on the average energy consumption/day for adults and children over 4 years of age in Australia and New Zealand and is sourced from:
Australian Bureau of Statistics (1998) National Nutrition Survey: Selected Highlights, Australia 1995. Australian Bureau of Statistics, Canberra.
and
Horwath C, Parnell W, Birkbeck J, Wilson N, Russell D and Herbison P. (1991) Life In New Zealand Survey Commission Report: Volume VI. Nutrition. University of Otago, Dunedin.
For example, according to figures from the US National Centre for Health Statistics, the average 4 year old girl is 101 cm tall and weighs 16 kg and the average 4 year old boy is 102 cm tall and 16 kg. On the other hand, the average 20 year old female is 164 cm tall and 58 kg while the average 20 year old male is 177 cm tall and 71 kg. The Australian methodology for calculating the reference values for daily energy intake combines information for ALL of these people. It makes an assumption that a 101 cm, 16 kg, 4 year old girl has the same energy requirements as a 177 cm, 71 kg, 20 year old male.
One must question the usefulness of a reference value that takes an average value from a sample set with such extreme differences in weight characteristics.
Protein value is based on average for RDI for men (55 g) and non-pregnant, non-lactating women (45 g) which are sourced from:
National Health and Medical Research Council (1991) Recommended Dietary Intakes for Use in Australia. AGPS Canberra.
Fat value is based on 30% of energy and sourced from:
National Health and Medical Research Council (1991) Recommended Dietary Intakes for Use in Australia. AGPS Canberra.
Commonwealth Department of Human Services and Health (1994) Better Health Outcomes for Australians. National Goals, Targets and Strategies for Better Health Outcomes into the Next Century. Commonwealth Department of Human Services and Health, Canberra.
Sugars value is based on 12% of energy and sourced from:
Commonwealth Department of Health. Towards Better Nutrition for Australians. Report of the Nutrition Taskforce of the Better Health Commission. AGPS Canberra, 1987.
Commonwealth Department of Health. Towards Better Nutrition for Australians. Report of the Nutrition Taskforce of the Better Health Commission. AGPS Canberra, 1987.
National Health and Medical Research Council (1991) Recommended Dietary Intakes for Use in Australia. AGPS Canberra
This highlights one of the fundamental flaws of percentage daily intake labelling – the meaning of each reference value is different.
While the sodium reference level is an absolute maximum for healthy consumption, the reference level of 50g per day for protein is in fact a minimum level for most adults. There is no indication on the percentage daily intake label whether the reference value is a minimum or a maximum or an exact target.
The traffic light system being trialled in the UK has the potential to be better in this regard as the colours green to red can be used to indicate whether higher or lower is better for a particular nutrient. However, under the current scheme being trialled in the UK, only nutrients such as total fat, saturated fat, sugars and salts for which lower intake is recommended are included on the label.
A further problem with the Australian reference values is that all of the sources are considered to be somewhat old and with the recent worldwide dramatic interest in obesity, there is obviously a need fro more up-to-date figures that would be representative and cognisant of consumption patterns and habits of today’s Australians and New Zealanders.
As can be seen from the references quoted above, the reference values are quoted from reports written in 1987, 1991 and 1994. There have been many reports published since then but they have not been used as references by FSANZ.
In 1985 and 1995 two “National Dietary Survey” were conducted and reported. Unfortunately, due to different methodologies these two surveys cannot be compared, although there have been some attempts to correlate results and make some comparisons. The reports of compilation of results from the 1985 and 1995 surveys have been met with serious criticisms and are poorly regarded by experts in the field.
The recent publication “Nutrient Reference Values for Australia and New Zealand”, published by National Health and Medical Research Council in early 2006 (mentioned above) has also been ignored by FSANZ. This document adopted the approach of the US/Canadian Dietary Reference Intakes (DRIs) but has varied some of the terminology, notably to retain the term ‘Recommended Dietary Intake’”.
FSANZ has suggested that Proposal P293 Nutrition, Health and Other Claims which will probably not use the data in the this latest publication, but as this Proposal will not be released as a Preliminary Final Assessment Report until March 2007 and presumably it will contain a Draft of the new Standard 1.2.7, then we shall have to be patient to see if FSANZ has rethought this process and hence what data FSANZ has used as the basis for general level claims for Sodium, Saturated Fat and Total Sugars.
FSANZ has also recently announced that a new survey would be undertaken, probably in 2007. However it is not known, as yet, what methodology will be used and will the results be comparable to either the 1985 or 1995 results.
The concept of percentage daily intakes relies on 15 year old data based on a non-existent theoretical person whose energy intake is the average of all humans aged 4 years and over and whose salt intake is at the maximum limit of healthy consumption. The fact that the daily intake values are given as a percentage, suggests that 100% is a perfect daily intake. However, if everyone was to follow a diet with 100% daily intake of all nutrients, an active 20 year old male might get half of their daily energy requirements, the inactive 20 year old female might consume up to 30% too much energy, the average elderly male will have a 40% deficiency in protein intake, and the entire population will be at risk of high blood pressure from consistently consuming sodium at daily maximum levels.